Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 1 of 102
`
`
`
`
`
`
` Exhibit 3
`
`
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 2 of 102
`Attachment B for US Patent No. 7,031,724 Against Lyft Accused Products
`
`
`Based on information presently available,1 Defendant AGIS Software Development LLC (“AGIS Software”) contends that
`
`Plaintiff Lyft Technologies Inc. (“Lyft” or “Plaintiff”) infringes claims 9, 12-16 (the “Asserted Claims”) of U.S. Patent No. 7,630,724
`(the “’724 Patent”) through the Accused Products, Services which are manufactured, sold, offered for sale, and/or used by Lyft.
`
`The Accused Products comprise the Lyft and Lyft Driver applications, servers, and services manufactured, used, or sold by Lyft,
`Inc. during and after 2016. AGIS Software reserves the right to seek leave of court to amend this list of Accused Products after the
`filing of an amended complaint or as discovery progresses.
`
`Lyft directly infringes each of the Asserted Claims by making, using, importing, testing, distributing, selling, and/or offering for
`sale the Accused Products in violation of 35 U.S.C. § 271(a).
`
`Lyft indirectly infringes the Asserted Claims in violation of 35 U.S.C. § 271(b) by inducing third parties, including its users
`
`and/or customers, to directly infringe through their operation and use of the Accused Products. Lyft has knowingly and intentionally
`induced this direct infringement by, inter alia, (i) selling, importing, or otherwise providing the Accused Products to third parties with
`the intent that the Accused Products will be operated and used in a manner that practices the Asserted Claims; and (ii) marketing and
`advertising the Accused Products. Lyft’s marketing and promotional materials for the Accused Products are found, for example, on
`Lyft’s website, and in App stores of operating systems for which the Accused Products are made available. For example, Lyft’s website
`offers customers instructions and/or manuals for the Accused Products that instruct customers to, among other things, use the accused
`services in the Accused Products. Lyft’s website also offers support to customers, including instruction to, among other things, use the
`Accused Products share location information with a group of users. Lyft knows, or should have known, that its actions will result in
`infringement of the Asserted Claims, or subjectively believes that there is a high probability that its actions will result in infringement
`of the Asserted Claims but has taken deliberate actions to avoid learning these facts.
`
`
`1 ThereThese infringement contentions are provided on a provisional basis to comply with the deadline for P.L.R. 3-1. However, at
`this time, there is no operative complaint asserting non-infringement of any patent claim in this action at this time., and these
`contentions are not responsive to any claim or cause of action. AGIS Software reserves the right to update itsthese contentions upon
`receipt of any futurean amended complaint. These March 18, 2022 amended contentions do not add or modify any theories of
`infringement and are provided solely for the purpose of making clear that AGIS Software does not allege infringement of any Lyft
`iOS-based applications and that AGIS Software does not rely on any Apple products.
`
`B-1
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 3 of 102
`Attachment B for US Patent No. 7,031,724 Against Lyft Accused Products
`
`
`Lyft also contributorily infringes each of the Asserted Claims in violation of 35 U.S.C. § 271(c) by selling, importing, offering
`
`for sale, and otherwise providing the Accused Products, which when used directly infringe the Asserted Claims. The Accused Products
`constitute a material part of the Asserted Claims.
`
`The following chart identifies specifically where each limitation of each Asserted Claim is found within the Accused Products,
`
`and in particular, the corresponding elements that meet the limitations in the Lyft and Lyft Driver applications, services, and services.
`On information and belief, each charted version of the Lyft Rider and Driver Apps are representative of all versions of the Accused
`Products, including all variants of the Accused Products made, sold, offered for sale, or used on any version of the Android and iOS
`operating systems. On information and belief, Lyft also has applications through other distribution platforms.
`
`AGIS Software does not concede that any claims of the ʼ724 Patent that are not listed below are not infringed by the identified
`
`Accused Products. Moreover, the citations to certain documents and other information below are intended to be exemplary only and in
`no way foreclose AGIS from citing or relying on additional documents, information, source code, and/or testimony at a later time. These
`contentions are preliminary in nature and an analysis of Lyft’s products, internal documentation, source code, and/or testimony from
`relevant witnesses may more fully and accurately describe the infringing features of its accused products. Accordingly, AGIS Software
`reserves the right to seek leave of court to supplement, correct, modify, and/or amend these contentions once such additional information
`is made available to AGIS Software. Furthermore, AGIS Software reserves the right to seek leave of court to supplement, correct,
`modify, and/or amend these contentions as discovery in this case progresses; in view of the Court’s claim construction order(s);2 in view
`of any positions taken by Lyft, including but not limited to positions on claim construction, invalidity, and/or non-infringement; and in
`connection with the preparation and exchange of expert reports.
`
`The contents of each claim cell below on which another claim cell depends are expressly incorporated by reference in that
`dependent cell, as if set forth in their entirety therein.
`
`
`2 The construction of claim terms herein is consistent with the constructions in AGIS Software Dev. LLC v. Huawei Device USA, Inc.,
`No. 2:17-cv-00513-JRG, Dkt. 205 (E.D. Tex. Oct. 10, 2018); AGIS Software Dev. LLC v. Google LLC, No. 2:19-cv-00361-JRG, Dkt.
`147 (E.D. Tex. Dec. 8, 2020); AGIS Software Dev. LLC v. T-Mobile USA, Inc., et al., No. 2:21-cv-00072-JRG, Dkt. 213 (E.D. Tex.
`Nov. 10, 2021). AGIS Software reserves the right to update its constructions and contentions in view of this Court’s claim
`construction order.
`
`B-2
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 4 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`for
`9[P]. A method
`providing a cellular phone
`communication network
`for
`designated
`participating users, each
`user having a similarly
`equipped cellular phone
`that includes a CPU, GPS
`navigational system, an
`interact
`message
`transmitter and receiver
`and a touch screen display
`comprising:
`
` Accused Products
`The Lyft Accused Products perform a computer implemented method as set forth below. Lyft further
`infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to the
`performance of: a method for providing a cellular phone communication network for designated
`participating users, each user having a similarly equipped cellular phone that includes a CPU, GPS
`navigational system, an interact message transmitter and receiver and a touch screen display.
`
`
`
`For example, Lyft provides Lyft app for passengers and Lyft Driver app for drivers. The Lyft apps for
`riders and drivers, in conjunction with Lyft’s servers and services, provide users with interactive methods
`to request, view, and track locations of passengers/riders using real-time maps and communications. The
`Lyft server(s) and their services communicate with the Lyft apps for riders and drivers. The Lyft server(s)
`and their services host information related to and instructions for processing user/device/vehicle
`accounts, location data, and map data. The claimed methods are distributed by Lyft in the Lyft apps.
`The claimed methods are used/tested by Lyft using the Lyft apps. The claimed methods are downloaded
`and
`installed by Lyft’s customers
`(riders) and personnel
`(drivers, personnel) at
`the
`direction/encouragement of Lyft and used by Lyft’s customers and Lyft’s personnel.
`. Each of the driver and the passenger’s mobile phones which are installed with the Lyft and Lyft driver
`apps comprises a CPU, GPS, a navigational system symbol generator (Lyft App and Lyft Driver App)
`and a touch screen display. The Lyft and Lyft Driver application is supported by smart devices including
`but not limited to smartphones and tablets, which have an antenna in them for both transmission and
`reception.
`
`
`B-3
`
`
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 5 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
` https://help.lyft.com/hc/en-ca/articles/115013079208-Lyft-Driver-app
`
`
` https://www.lyft.com/drive-with-lyft
`
`
`
`
`
`
`
`
`B-4
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 6 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
` https://www.lyft.com/hub/posts/how-to-give-a-ride
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`B-5
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 7 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`
`
`B-6
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 8 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`B-7
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 9 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
`
`
`B-8
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 10 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
`
` https://apps.apple.com/in/app/lyft/id529379082
`
`B-9
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 11 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-10
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 12 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-11
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 13 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
`https://www.androidauthority.com/what-is-an-soc-smartphone-chipsets-explained-1051600/
`
`
`
`
`B-12
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 14 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://www.cashify.in/how-to-turn-off-gps-on-any-android-or-ios-device
`
`
`
`
`B-13
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 15 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
`
`
` https://www.electronics-notes.com/articles/connectivity/cellular-mobile-phone/how-cellphone-works-
`inside-components.php
`
`
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Lyft
`and to the extent Lyft requires additional information in accordance with P.R. 3-1 and for any other
`reasons.
`The Lyft Accused Products perform a computer implemented method as set forth below. Lyft further
`infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to the
`performance of: accessing a database in each cell phone that includes a geographical map of a
`predetermined area for user viewing on the touch screen display.
`
`
`
`9[A] accessing a database
`in each cell phone that
`includes a geographical
`map of a predetermined
`area for user viewing on
`the touch screen display;
`
`B-14
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 16 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`For example, in the Lyft app for passengers, the passenger will receive a geographical location on the
`map on the display of their mobile phone. The geographical map is accessed through the database of the
`Lyft app. Through this geographical map, the passenger is able to make a ride request to a particular
`location and see the location of different nearby drivers before making the request and viewing the
`location of the driver after a driver accepts the passenger’s ride request.
`
`For example, in the Lyft driver app, the driver will receive a geographical map of their location, which
`is accessed through the database of the Lyft driver application. Through this app, the driver is able to see
`the location of the rider, when the ride request message of the passenger is broadcasted with the
`passenger’s pickup location (provided pickup location is set to the current location by the passenger).
`
`
`B-15
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 17 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`B-16
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 18 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
`Nearby
`Drivers’
`location
`
`Passenger’s
`location
`
`
`
`
`
`
`
`
`B-17
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 19 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 3:27
`
`
`
`B-18
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 20 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-19
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 21 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-20
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 22 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 4:01
`
`
`
`B-21
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 23 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
`
`
`B-22
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 24 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-23
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 25 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
`Driver’s device
`displaying
`passenger’s ride
`request message
`
`Passenger’s
`current location
`(when pickup
`location is set to
`current location)
`
`Driver’s current
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:24, Annotated
`
`
`
`B-24
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 26 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`B-25
`
`
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 27 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
`Driver’s mobile
`phone screen
`
`Passenger’s
`current location
`(when pickup
`location is set to
`current location)
`
`Driver’s current
`location
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46, Annotated
`
`
`
`B-26
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 28 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`B-27
`
`
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 29 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
`Passenger’s
`mobile phone
`screen
`
`Passenger’s
`current location
`(when pickup
`location is set to
`current location)
`
`Driver’s current
`location
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07, Annotated
`
`
`
`B-28
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 30 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s ride
`request message
`
`Driver’s
`location
`
`Passenger
`pickup
`location
`(purple dot)
`
`B-29
`
`
`
`

`

`
`
`Claim – 7,630,724
`
`an
`accessing
`9[B].
`in
`application program
`for
`each
`cell phone
`generating one or more
`symbols representative of
`one or more participating
`users, each of whom have
`a
`similarly
`equipped
`cellular phone;
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 31 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Lyft
`and to the extent Lyft requires additional information in accordance with P.R. 3-1 and for any other
`reasons.
`
`The Lyft Accused Product(s) performs a computer implemented method as set forth below. Lyft further
`infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to the
`performance of: accessing an application program in each cell phone for generating one or more symbols
`representative of one or more participating users, each of whom have a similarly equipped cellular phone.
`
`
`
`For example, Lyft app displays symbols on the screen representing the passenger as well as the driver’s
`vehicle.
`
`
`B-30
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 32 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07
`
`
`
`B-31
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 33 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Passenger’s device
`displaying
`passenger’s location
`(bluepink dot)
`
`Driver’s
`location
`
`B-32
`
`
`
`

`

`
`
`Claim – 7,630,724
`
`9[C]. accessing a database
`in each cell phone that
`includes cellular telephone
`numbers of each of the
`participating users having
`similarly equipped cellular
`phones,
`said database
`including the generation
`of one or more symbols
`associated
`with
`a
`particular
`participating
`user;
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 34 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Lyft
`and to the extent Lyft requires additional information in accordance with P.R. 3-1 and for any other
`reasons.
`
`
`
`The Lyft Accused Products perform a computer implemented method as set forth below. Lyft further
`infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to the
`performance of: accessing a database in each cell phone that includes cellular telephone numbers of each
`of the participating users having similarly equipped cellular phones, said database including the
`generation of one or more symbols associated with a particular participating user.
`
`
`
`The Lyft apps meet this limitation because they access the virtual telephone numbers or the unique
`identifiers which are equivalent to phone numbers of the riders/drivers of the Lyft platform/network. The
`virtual phone numbers are received and kept on one or more databases either locally or remotely on a
`Lyft server(s) for access by the Lyft apps. For example, when the driver is matched to the passenger,
`both the driver and the passenger get the call icon (“rapid voice initiation and communication”) on their
`respective mobile phones display in the Lyft driver and Lyft app respectively through which both of them
`call each other by tapping the call icon on their respective touch screen display.
`
`
`B-33
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 35 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07
`
`
`
`B-34
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 36 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-35
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 37 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-36
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 38 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46
`
`
`
`B-37
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 39 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-38
`
`

`

`
`
`Claim – 7,630,724
`
`a
`calling
`9[D].
`by
`participating
`user
`touching the symbol on
`the map display and
`touching a call switch;
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 40 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Lyft
`and to the extent Lyft requires additional information in accordance with P.R. 3-1 and for any other
`reasons.
`
`With respect to the limitations reciting the cellular phone number(s) or telephone number(s), the claim
`is met either literally or under the doctrine of equivalents.
`
`See claim 9[C].
`
`The Lyft Accused Products perform a computer implemented method as set forth below. Lyft further
`infringes directly and/or indirectly by performing, inducing others to perform, and/or contributing to the
`performance of: calling a participating user by touching the symbol on the map display and touching a
`call switch.
`
`
`
`The Lyft apps meet this limitation because provide selectable interface elements on the Lyft application
`for calling drivers/riders. For example, when the driver is matched to the passenger, both the driver and
`the passenger get the call icon (“rapid voice initiation and communication”) on their respective mobile
`phones display in the Lyft driver and Lyft app respectively through which both of them call each other
`by tapping the call icon on their respective touch screen display.
`
`
`B-39
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 41 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07
`
`
`
`B-40
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 42 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-41
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 43 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46
`
`
`
`
`B-42
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 44 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-43
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 45 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46
`
`
`
`B-44
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 46 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-45
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 47 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-46
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 48 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 11:21
`
`
`
`B-47
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 49 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-48
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 50 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-49
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 51 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07
`
`
`
`B-50
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 52 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-51
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 53 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:32
`
`
`
`B-52
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 54 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-53
`
`

`

`
`
`Claim – 7,630,724
`
`9[E]. connecting each of
`the cell phones
`to an
`internet connection;
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 55 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Lyft
`and to the extent Lyft requires additional information in accordance with P.R. 3-1 and for any other
`reasons.
`
`
`The Lyft Accused Products infringes directly and/or indirectly by performing, inducing others to
`perform, and/or contributing to the performance of: connecting each of the cell phones to an internet
`connection.
`
`
`
`For example, when passengers and drivers access the Lyft and Lyft driver apps respectivelywhich are
`connected to an IP based connection for them to use the Lyft platform (Lyft and Lyft Driver app).
`
`
`B-54
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 56 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`
` Accused Products
`
` https://help.lyft.com/hc/e/articles/115013080508-Phone-software-recommendations-and-settings
`
`
`Further, to the extent this element is performed at least in part by Lyft's software source code, AGIS
`reserves the right to supplement these contentions pursuant to production of such source code by Lyft
`and to the extent Lyft requires additional information in accordance with P.R. 3-1 and for any other
`reasons.
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform,
`and/or contributing to the performance of: exchanging IP addresses using SMS or other digital message
`format between and among each of the network participant users so that communications between
`
`
`
`IP
`exchanging
`9[F].
`addresses using SMS or
`other
`digital message
`format
`between
`and
`
`B-55
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 57 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`Claim – 7,630,724
`the
`among
`each
`of
`network participant users
`so that communications
`between participants
`is
`established via
`IP or
`transmission of a network
`participant's IP address to
`a
`server which
`then
`transmits data
`to other
`network participants using
`the IP address previously.
`
` Accused Products
`participants is established via IP or transmission of a network participant's IP address to a server which
`then transmits data to other network participants using the IP address previously.
`
`
`
`The Lyft apps meet this limitation because the Lyft apps transmit data (including their IP addresses) to
`the Lyft server(s) which then communicates data to the other rider/driver. Alternatively, the Lyft apps
`communicate IP addresses via the Lyft server(s) while communicating data between riders/drivers.
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 10:46
`
`
`
`B-56
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 58 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-57
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 59 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=jVUy9poJDng at 11:21
`
`
`
`B-58
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 60 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-59
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 61 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-60
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 62 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:07
`
`
`
`B-61
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 63 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-62
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 64 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
` https://www.youtube.com/watch?v=j0RDMLcmOgU at 5:32
`
`
`
`B-63
`
`

`

`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 65 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
`
`
`
`
`B-64
`
`

`

`
`
`Claim – 7,630,724
`
`Case 5:21-cv-04653-BLF Document 104-3 Filed 04/18/22 Page 66 of 102
`Attachment B for US Patent No. 7,630,724 Against Lyft Accused Products
`
` Accused Products
`
`
`
`
` https://www.open.edu/openlearncreate/mod/oucontent/view.php?id=129584&printable=1
`
`
`The Lyft Accused Products infringe directly and/or indirectly by performing, inducing others to perform,
`and/or contributing to the performance of: adding a new cell phone participant into a communication
`network of participating users by having the new cell phone participant transmit an identifier, a cell phone
`number and an IP address in an initial message to other participant users or to a server for retransmission
`of the data other network participants.
`
`
`Lyft meets this limitation because riders/drivers add their account/identity information which includes
`their cell phone number. Additionally, when using the Lyft app, IP based communication to the Lyft
`server(s) includes IP addresses.
`For example, Lyft’s ser